5683 Hines Drive Ann Arbor, Michigan 48108 www.tecumseh.com Exhibit 1.01 Tecumseh Products Company Conflict Minerals Report In accordance with Rule 13p-1 and Form SD under the Securities Exchange Act of 1934 For the reporting period from January 1, 2014 to December 31, 2014 This is the Conflict Minerals Report (“CMR”) of Tecumseh Products Company (“Tecumseh”, “Company”, “we”, “us” or “our”) for calendar year 2014 prepared in accordance with Rule 13p-1 and Form SD promulgated under the Securities Exchange Act of 1934 (the “Rule”). Section 1: Introduction The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals, which we collectively refer to in this Report as the “Conflict Minerals” or “3TG”, are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (excepting any of the foregoing that, prior to January 31, 2013, were located outside of the supply chain). The “Covered Countries” for purposes of the rule are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this CMR, certain of our operations manufacture, or contract to manufacture, products and the Conflict Minerals are necessary to the functionality or production of those products. Section 2: Product Description Tecumseh is a global manufacturer of hermetically sealed compressors for residential and specialty air conditioning, household refrigerators and freezers and commercial refrigeration applications. This Report relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by Tecumseh; and (iii) for which the manufacture was completed during calendar year 2014. These products, which are referred to in this Report collectively as the “Covered Products”, are air conditioning and refrigeration compressors, condensing units, heat pumps and complete refrigeration systems for (i) commercial refrigeration applications, including walk-in coolers and freezers, ice makers, dehumidifiers, water coolers, food service equipment and refrigerated display cases and vending machines; (ii) household refrigerators and freezers; and (iii) residential and specialty air conditioning and heat pumps, including window air conditioners, packaged terminal air conditioners and recreational vehicle and mobile air conditioners. These compressors include reciprocating piston models, rotary compressors and scroll compressors. With the assistance of our third-party service provider, we have determined that our compressors, condensing units, heat pumps and complete refrigeration systems contain Conflict Minerals that are necessary to the functionality or production of that product, including tin in all of our compressors, tungsten in our rotary compressors, and gold and tantalum in our condenser units.
Transcript
5683 Hines Drive Ann Arbor, Michigan 48108
www.tecumseh.com
Exhibit 1.01
Tecumseh Products Company
Conflict Minerals Report
In accordance with Rule 13p-1 and Form SD under the Securities Exchange Act of 1934
For the reporting period from January 1, 2014 to December 31, 2014
This is the Conflict Minerals Report (“CMR”) of Tecumseh Products Company (“Tecumseh”, “Company”, “we”, “us” or
“our”) for calendar year 2014 prepared in accordance with Rule 13p-1 and Form SD promulgated under the Securities
Exchange Act of 1934 (the “Rule”).
Section 1: Introduction
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and
the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals,
which we collectively refer to in this Report as the “Conflict Minerals” or “3TG”, are gold, columbite-tantalite (coltan),
cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (excepting any of the
foregoing that, prior to January 31, 2013, were located outside of the supply chain). The “Covered Countries” for purposes of
the rule are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan,
Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.
As described in this CMR, certain of our operations manufacture, or contract to manufacture, products and the Conflict
Minerals are necessary to the functionality or production of those products.
Section 2: Product Description
Tecumseh is a global manufacturer of hermetically sealed compressors for residential and specialty air conditioning, household
refrigerators and freezers and commercial refrigeration applications. This Report relates to products: (i) for which Conflict
Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be
manufactured, by Tecumseh; and (iii) for which the manufacture was completed during calendar year 2014.
These products, which are referred to in this Report collectively as the “Covered Products”, are air conditioning and
refrigeration compressors, condensing units, heat pumps and complete refrigeration systems for (i) commercial refrigeration
applications, including walk-in coolers and freezers, ice makers, dehumidifiers, water coolers, food service equipment and
refrigerated display cases and vending machines; (ii) household refrigerators and freezers; and (iii) residential and specialty air
conditioning and heat pumps, including window air conditioners, packaged terminal air conditioners and recreational vehicle
and mobile air conditioners. These compressors include reciprocating piston models, rotary compressors and scroll
compressors.
With the assistance of our third-party service provider, we have determined that our compressors, condensing units, heat pumps
and complete refrigeration systems contain Conflict Minerals that are necessary to the functionality or production of that
product, including tin in all of our compressors, tungsten in our rotary compressors, and gold and tantalum in our condenser
units.
5683 Hines Drive Ann Arbor, Michigan 48108
www.tecumseh.com
Section 3: Reasonable Country of Origin Inquiry
We have conducted the procedures described in Section 3 below as our good faith reasonable country of origin inquiry
(“RCOI”) regarding the Conflict Minerals. The RCOI was reasonably designed to determine whether any of the Conflict
Materials in our Covered Products originated in the Covered Countries and whether any of the Conflict Minerals may be from
recycled or scrap sources.
With the assistance of our third-party service provider, we identified direct suppliers who supply us with metals, electronics, or
with product components containing metals or electronics for our Covered Products.
With the assistance of our third-party service provider, suppliers were provided with background materials regarding Conflict
Minerals, the disclosure Rule and our supplier policies regarding Conflict Minerals and were requested to use the Electronic
Industry Citizenship Coalition and Global e-Sustainability Initiative (“EICC/GeSI”) Conflict Minerals Reporting Template
(“CMRT”) to identify our 3TG supply chain participants, including smelters and refiners (“SORs”), mines and associated
countries of origin of the Conflict Minerals in our Covered Products. Our supply chain with respect to the Covered Products is
complex, and we believe there are many third parties in the supply chain between the ultimate manufacturer of the Covered
Products and the original sources of the Conflict Minerals. In this regard, we do not purchase Conflict Minerals directly from
mines, smelters or refiners. We must therefore rely on our suppliers to provide information regarding the origin of Conflict
Minerals that are included in the Covered Products. Moreover, we believe that smelters and refiners of the Conflict Minerals
are best situated to identify the sources of the Conflict Minerals.
Below is a summary of SORs identified by our suppliers for 2014 and their status (based on available lists of SORs certified by
The smelter is certified as conflict-free by the Conflict Free Sourcing Initiative
(“CFSI”) through the Conflict-Free Smelter Program (“CFSP”) for the metal as either
not originating in Covered Countries or not directly or indirectly financing or
benefitting armed groups in Covered Countries.
CFSI - Active - [Metal]
The smelter is actively pursuing CFSI certification. This may mean either the smelter
was not previously certified and is now actively pursuing CFSI certification or the
smelter's certification expired and it is in the renewal process.
CFSI - Progressing - Tungsten Tungsten smelters that have committed to obtain a CFSI certification within 2 years
of membership with the Tungsten Industry - Conflict Minerals Committee (TI-CMC).
CFSI - Verified Verified as a smelter by the CFSI, yet to be certified.
LBMA
The London Bullion Market Association (“LBMA”) is an international trade
association representing the London market for gold and silver bullion refiners. It
produces Good Delivery Lists for gold and silver bars; detailing the names of
accredited refiners, their listing date and the marking details of their bars. The LBMA
Good Delivery gold refiners are conflict-free due to compliance with an audited,
conflict-free process through LBMA’s Responsible Gold Guidance aligned with
OECD Due Diligence requirements.
LBMA - Pending The LBMA indicates the smelter is working on a Responsible Gold Certificate.
RJC
The Responsible Jewelery Council (“RJC”) is a certification body for diamonds, gold
and platinum group metals. The RJC Chain-of-Custody (“CoC”) certification,
applicable to gold and platinum group metals, certifies refiners as responsibly
sourced, which is conflict-free as a minimum, and responsibly produced at each step
of the supply chain. It assists companies to conform to the OECD Due Diligence
Guidance, LBMA Responsible Gold Guidance and the EICC Smelter/Refiner
Validation Program, and to comply with the provisions of the US Dodd-Frank Act
(Section 1502, Conflict Minerals).
The Conflict Minerals supplied by the SORs listed above may be from the following countries (based on responses to the
CMRTs and follow-up inquiries, government listings, smelter certification bodies and internet research conducted by the
third-party service provider):
Argentina, Armenia, Australia, Austria, Bolivia, Brazil, Burundi, Canada, Chile, China, the Democratic Republic of the
Congo, Ethiopia, France, Ghana, Guinea, Guyana, India, Indonesia, Italy, Japan, Kazakhstan, Kyrgyzstan, Laos,
Malaysia, Mali, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Niger, Nigeria, Papua New Guinea, Peru,
Philippines, Portugal, Russia, Rwanda, Saudi Arabia, South Africa, South Korea, Spain, Suriname, Sweden, Taiwan,
Tajikistan, Thailand, Turkey, United Arab Emirates, United Kingdom, United States, Uzbekistan, and Vietnam.
Because our RCOI revealed that the countries of origin for necessary Conflict Minerals in the supply chain for our Covered
Products may have included Covered Countries, we have reason to believe that some of our necessary Conflict Minerals may
have originated in Covered Countries and, therefore, are required to describe the subsequent measures we have taken to
exercise due diligence on the source and chain of custody of those Conflict Minerals.
5683 Hines Drive Ann Arbor, Michigan 48108
www.tecumseh.com
Section 4: Design of Due Diligence Measures
Our due diligence measures have been designed to conform to the framwork in the Organization for Economic Cooperation and
Developments ("OECD's") Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and
High-Risk Areas, Second Edition, including the related supplements1 ("OECD Guidance"). It is important to note that the
OECD Guidance was written for both upstream2 and downstream3 companies in the supply chain. As Tecumseh is a
downstream company in the supply chain, our due diligence practices were tailored accordingly.
Section 5: Due Diligence Measures Implemented
Due Diligence measures undertaken by Tecumseh on the source and chain of custody of its Conflict Materials with respect to
2014 included the following. These measures are consistent with the five steps of the OECD Guidance.
1. Establish strong company management systems
• We have adopted a conflict minerals policy supporting responsible sourcing and greater transparency in the supply
chain. The conflict minerals policy is publicly available at http://www.tecumseh.com/en/corporate/global-
suppliers/conflict-minerals. However, responsible sourcing is just one factor we consider in selecting our suppliers.
• We have assembled an internal Conflict Minerals Team to support supply chain due diligence- including members
from our Finance, Procurement and Internal Audit departments.
• Regional buyers assisted with direct communication with suppliers to request conflict minerals information in the
form of the CMRT.
• We have established a company website link for stakeholders who may have questions regarding Tecumseh’s Conflict
Minerals Program.
• We used a third-party service provider’s cloud-based data collection platform to gather information from suppliers in
the form of CMRT.
2. Identify and assess risks in the supply chain
After our RCOI determination was made:
• With the assistance of our third-party service provider, we implemented a survey of the portion of our supply chain
that supplies us with metals, electronics or with product components containing metals or electronics for our Covered
Products using the CMRT. Using the CMRT and our third-party service provider’s platform for data collection,
suppliers indicated the smelter and refiners and country of origin information with respect to the Conflict Materials
used in our Covered Products.
• Information was reviewed and suppliers were re-contacted with respect to incomplete or potentially inaccurate
responses, as needed, and for additional information regarding the source and chain of custody of the Conflict
Minerals used in our Covered Products.
• Smelters and refiners identified through the survey process were reviewed to determine if they were certified as
“conflict free” by the Conflict Free Smelter Program or other independent third party programs.
3. Design and implement a strategy to respond to identified risks
• We have designed and implemented a strategy to respond to supply chain risks. This strategy is shared with our
Conflict Minerals internal team, regional buyers, and suppliers through applicable sections of the Global Quality
Supplier Manual and the Global Purchase Order Terms and Conditions, located on our website.
• Identified risks or concerns are reported to senior management. 1OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Supplements on Tin, Tantalum and
Tungsten and Supplement on Gold, 2013; http://www.oecd.org/daf/inv/mne/GuidanceEdition2.pdf.
2Upstream companies refer to those between the mine and SOR. As such, the companies typically include miners, local traders, or exporters from the country
of mineral origin, international concentrate traders and SORs.
3Downstream companies refer to those entities between the SOR and retailer. As such, the companies typically include metal traders and exchanges, component
manufacturers, product manufacturers, original equipment manufacturers (OEMs) and retailers.
5683 Hines Drive Ann Arbor, Michigan 48108
www.tecumseh.com
4. Carry out independent third-party audit of supply chain due diligence practices
• The Company relies on the CFSI, LBMA, and RJC to conduct audits of smelters and refiners in its supply chain.
5. Report annually on supply chain due diligence
• Tecumseh’s Form SD and CMR is publicly available at http://www.tecumseh.com/en/corporate/global-
suppliers/conflict-minerals.
Section 6: Steps to Improve Due Diligence
During 2015, we expect to take the following steps to improve our supply chain due diligence efforts and to further mitigate the
risk that the necessary Conflict Minerals contained in our Covered Products finance or benefit armed groups in the Covered
Countries:
▪ Continue to assess the presence of 3TG in our supply chain.
▪ Continue to compare our identified SORs to certifications by independent conflict free smelter validation programs,
such as the CFSI’s Conflict-Free Smelter Program.
▪ Continue to encourage suppliers to support and implement responsible sourcing and greater transparency in the supply
chain and cooperate with our due diligence compliance efforts and identify and update the sources of Conflict
Minerals in their supply chains.
▪ Continue to follow-up appropriately when information provided by suppliers appears to be incomplete, incorrect or
when further inquiry of the suppliers is necessary to identify the source and chain of custody of the Conflict Minerals
used in our Covered Products, including the related SORs and the mine or location of origin of such Conflict Minerals.
Forward-Looking Statements
This report contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act that are
subject to the safe harbor provisions created by that Act. Any statements that do not relate to historical or current facts or
matters are forward-looking statements. Forward-looking statements can be identified by the use of terms such as “expects,”
“should,” “may,” “believes,” “anticipates,” “will,” and other future tense and forward-looking terminology. Statements
concerning current conditions may also be forward-looking if they imply a continuation of current conditions. Examples of
forward-looking statements include, but are not limited to, statements in Section 6 of this CMR, statements concerning our
intended future efforts to mitigate the risk that the manufacture of our products benefits armed groups in the Covered Countries.
Forward-looking statements are subject to risks and uncertainties that could cause actual actions or performance to differ
materially from those expressed in the forward-looking statements. These risks and uncertainties may include, but are not
limited to, the implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers,
on a timely basis or at all, whether smelters and refiners and other market participants responsibly source Conflict Minerals and
political and regulatory developments, whether in the Covered Countries, the United States, or elsewhere. You are cautioned
not to place undue reliance on these forward-looking statements, which speak only as of the date of filing of this document. We
do not intend, and undertake no obligation, to update or revise the forward-looking statements, whether as a result of new
information, future events or circumstances or otherwise.
5683 Hines Drive Ann Arbor, Michigan 48108
www.tecumseh.com
Section 7: Product Determination
Based on our knowledge, after performing the procedures described above, we do not have sufficient information, with respect
to the Covered Products to determine any of the facilities that were used to process the Conflict Minerals contained in the
Covered Products, except as provided in Section 3.
Based on our knowledge, after preforming the procedures described above, we do not have sufficient information with respect
to the Covered Products to determine the country of origin of the Conflict Minerals in the Covered Products, except as provided
in Section 3.
Except for the procedures described above, we have not undertaken any other efforts to determine the mine or location of origin
with the greatest possible specificity of the Conflict Minerals in the Covered Products.
